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Changes to Secondary Containment and Overfill Device Regulations

Today we’re going to discuss the pre regulations as they relate to underground storage tank overfill protections. I’m going to talk a little bit about how to meet those mandates and some best practices and before we get started. Let me introduce our speaker and we’ll get right into our content here. So today’s presenter is Lee Girard and so Lee Gerard is our life cycle management, product manager for the atg platform here veeder root Lee’s got some extensive. Experience has got over 25 years of industry. Experience related to 80 G’s favor recovery devices, fuel flow, submersible pumps is well as hanging. Hardware he’s got a great background. It not only you know, sales experience perience, but he also has a technical field background as well, so without any further delay, i’m going to go ahead and turn it over to Lee and we’ll get started.

Okay, great job appreciate it. Thank you everybody for joining today. We really appreciate you taking the time out of your busy schedule. Hopefully this is something that will benefit all and it’s anything, a good reference point for making sure that now, if you’re an end user or distributor or just plain as a contractor out there, you know you’re dealing with the regulations correctly.

So so there’s there’s five things. We’Re basically going to try to cover today in the next 30 minutes, so we’re going to talk a little about the regulations and the timeline for overfill and secondary containment make a real quick snapshot of that talk about the new overfill protection regulation methods. Then we’ll want to talk about the secondary containment regulations, because that’s always good to know and more importantly, it’s something that is getting closer and closer from a standpoint from a date requirement. And then we review the UST release, detection requirements that are out there and that are part of the new regs and then the last thing I want to cover just to make sure everybody has a good understanding. Is the new equipment maintenance regulations because you know ultimately, all this equipment that you’re working on or managing or having to manage at your location? You have to meet immediate requirement.

So let’s talk about the time line first on the on the EPA side of it. So this is just kind of a visual for everybody. In July of 2015, the EPA published their new underground storage tank regulations now moving a little bit further into the fall of last year. You know that this is really about the overfill side of it flow restrictors. In the vent lines may no longer be used, so some of you who’ve been in the industry for a while understand that you know the ball float valve system is really the flow restrictors are out there and they really remove them from the regulations because they didn’t Feel that they provided the adequate protection in an oil field condition now moving forward to this year in april of 2016, no owners and operators must begin meeting these requirements and what some of the requirements are secondary, containment and institutional monitoring for new and replaced tanks and Piping, so if you replace the tank or replace piping they’re requiring for you to use interstitial monitoring for those types of piping and tank systems and then the other aspect that is they’re gon na be looking for under dispense your containment for new dispenser systems. So that means they’re going to want you to make sure that you have some type of containment system under the dispensers and ultimately they’re going to want you to monitor that now going forward a couple years down the road here, owners and operators are going to have To start conducting bases their first test and start doing inspections, so they have to inspect things like the spill prevention equipment.

The overfill prevention equipment and they’re also got the test, containment, salt and testings a little stumps and any piping related to that. Also from an interstitial perspective and then also the release, detection equipment is going to have to be tested and we’ll talk about that. The end this is the last class I have and then basic walkthrough inspections. Let’S talk about the overfill protection and the changes. The EPA regulations of come forth so back in 1998. You know all underground storage tanks that had deliveries of 25 gallons must have or more must have an overfill protection device installed and and if you’ve been around for a wild, isn’t there’s multiple types of devices out there. You have an automatic shutoff device, which is a flapper valve which is probably installed, and you know sixty seventy percent of those pings out there an overfill alarm. So if you have a like a meter, vtg system, you can connect an external device that will will produce an alarm condition when you meet a certain threshold, it’s programmed in the console and then the last one is the ball float valve that I talked about earlier. So again, as octobre 13, these then pipe falls. Both valves are no longer be acceptable, and you know the real reason is because you know that they don’t feel that they they provide the right protection and then there’s there’s requirements for the ball valve to work properly, and they found that those ball valves actually fail Of more often than not so here’s a lil bit about the the ball valve from the ball float valve. That’S not accepted so the ball flow valve you know basically would alert the delivery driver, not the at Memphis station operator of an over filled conditions reached and basically what happens is it restricts the the vent line that goes back through the line to the tank, which Now, technically creates a pressure change in the in the vent line on the truck that’s delivering product and then, ultimately, the alerts, the driver, because of that change in pressure and that supposed to indicate to the driver, hey it’s time to stop delivering problem with dies. Does the drivers not being attention he’s, not you know he’s on the other side of the truck doing something he could possibly not see. That condition occur as it’s occurring and potentially over fill the tank. Now the Volvo belts cause wear and tear on the UST system, because it’s causing you no change in pressurization and the tanks and in the line. So ultimately, you could also cause issues with your tank and lines because of this product. Now some basic principles behind overfill commissions and those of you who have been out there for a while and the industry probably seen these experience them. You haven’t. This is within the ground typically. So if you have an automatic tank gauge system like the V root system, we have a probe in the tank that probe can read them into our levels. That probe can also be programmed through the tank age to sound, an audible alert at ninety percent points. In a fill or delivery condition, and then over to the right, this indicator here is overfill alarm and you may have one at your site today loves that the driver and flashes of light and and tells them hey you’re over filling the tank. The driver can use an acknowledgement device that we have to this box technology alarm condition after he is shut down the valve to ensure he doesn’t fill the tank. So that’s the less the detg side of it when it comes to overfill production.

The second one that you can use is the flapper valve. Now this is designed to restrict flow a product around ninety five percent. In the tank, the drivers learned when the delivery ho starts jumping from a hydraulic shock. That’S really what happens and the ball valve inside this flapper when the back flapper valve goes up, restricts flow and then it restricts the product going back into the tank. So these do work. They were Phil alarm on. The atg is a great tool to have the flapper valve is, is uh is a great tool also, but we feel that you know these solutions together, help each other, because if the fiber valve fails for some reason used to it – and you have it in, you Have a probe in the tank and you got an atg monitoring the tank. You now have a secondary device to ensure that you don’t overfill. Ok now. Obviously you can use one method based on the regulation. But again, if you have an EEG already installed at your site, you have that capability like to be the roof to be able to produce this external alarm and light indicator. Now, one of the things you might want to check locally, if you have to deal with local regulations, is make sure that the state and the local level they they. They require certain protections so we’re finding that some regulatory bodies require redundant protection methods such as what I just talked about the flapper valve and the atg, such as verify that with your local agency. So why implement to protection methods, as fiber valves really does not sufficient for sale protection? Most people who don’t use the view or an EEG for overfill production feel the flapper valve their usual legalizing. It is sufficient, however, you know installation errors can cause the system not to work properly. The flapper valve can be easily defeated, so people can like this particular example.

Some extra screw down the shuttle and it would never fly, never open up, so they are probably packing their tank as much as possible because there’s an opportunity for them to be able to fill the tank up to ninety five hundred percent. Now, when the flower belt does fail, there’s no learning of that failure. Nobody knows about it. So and that’s one of the risk you take of using justify prevail by itself, and then you know many flower valves require removal to test. So again you have to get somebody out there. They got to perform an annual test and then they got to make sure that the system works properly. Now some of the advantages of used in an overfill alarm, that’s connected to an AEG. It’S a single overfill alarm unit has advantages to alert the driver dropping product, the operator at the store, and if you utilizing remote connectivity types of devices that you can use in most acgs like to be a room for 50 plus it can email somebody it can. It can send them a notification to let them know that the tanks being over filled, which is really important if you’re the operator owner of that station. You want to know what’s going on. Obviously your your site, um, it doesn’t it’s not susceptible to mechanical failures. It’S really tough to to feed it. Some you have to pretty much disable. It says to get it not to work, so some of you have to physically remove the ball or remove the buzzer to stop its functioning. Most of these are installed 10 15 feet in the air and be very difficult for them, and do that and what’s nice about the the overfill protection devices that are out there, such as the V droop or go alarm, is that you can go in into a Periodic test on it: it’s pretty straightforward, you know you could slide the inventory provo in the tank that create the alarm and it’s on the buzzer, and we also have a test button on the side of the device make sure the device is still powered up and Working properly so love about the overfill inspection requirements, so what’s coming, is every 30 days they’re requiring you to do some type of digital inspection to ensure the devices that you’re using or not damaged or defective these route. Basically, we recommend that you use that test button. I talk about a second ago on you’ll feel switch to make sure that there’s power to it, the light works and the buzzer works. If that’s the case and it’s connected to the veeru, it will work it when there’s no more field condition now moving forward. Every three years you get a test, the equipment and activate it to make sure it works at the ninety percent level. So for the BT root system, you got to move to move the probe float, so it stimulates the delivery and it goes exceeds the ninety percent level as program in the console and make sure it generates that alarm externally and internally. And then, if you have the shut-off devices, you have to make sure that it activates it and prevents product from reaching that height of ninety-five percent. Now, on the owner/operator side, it is you know, what’s the best practice for the owner/operator here, so ensure that there’s enough room in the tank before each delivery – and you know you folks that are out there who have been doing this for a long time who operate The sites you know you look at the video route: 80 g, all the time for inventory water, the tanks in your all into your available space. So make sure you interpret that and then, if you’re, using that to call delivery, drivers make sure you’re accurate. With that information, that’s really the key, monitor all your fuel deliveries from beginning to end. There’S a lot of situations where even the drivers don’t pay attention, while they’re delivering product and they end up we’re filling the tank and causing an environmental issue inspect those fill buckets. You know before and after deliveries, if you can, because that’s important to know you know how well the delivery went and also if the driver took care of the spill in that spill. Bug gifts on the news, Phil bug is how a plunger that allows that product go back in the tank and simply just pulling on it allows the product to go into the tank, the ones that don’t. As you can see the lower picture. Here you got to pump it out and report that now, let’s switch gears a little bit we’ll talk about secondary containment regulations, so pertains and piping installed after April this year, um they must have secondary type of containment with interstitial monitoring. So that basically means you get that some type of interstitial sensor device like we have with the viewer systems, where you can make sure that if there is a liquid condition in those containment areas or interstitial spaces, the VT routes going to alarm at you. And let you know you have a condition that you each with dress now the secondary containment definition here says basically: release prevention system has an inner and outer barrier with an inner social space that is modern for leaks, includes containment thumbs when used by in a system Ready for piping, so just keep that in mind. If you have secondary and double wall protection today and you’re, not monitoring them, the sensors you’re going to be you’re going to have to move forward at some point to go ahead and get some sensors installed.

Two is one regulatory bodies like that: they know that you’re being proactive, making sure you’re monitoring those those secondary areas to prevent potentially environmental issues and a typical and installation. You know the tank, the double wall, construction with interstitial monitoring center, so we have different types of sentences. We have a beetroot and other 80 G’s to be able to monitor that we have some the discriminate between water and fuel. Something just tell you. There’S liquid double wall piping, same thing: we multis multiple sensors out there that can detect liquid or detect the difference between water and fuel and shut down the site of it, needs you and then on the containment sums again. It is combination of different types of sensors. You can use for those applications little bit more about the secondary containment regulations on the testing side of it so again, beginning in on October of 2008. Hores operators must meet one of the following for spill: containment, equipment for containment sums using a pipe being interstitial monitoring device. So ultimately, so I’m not going to read through this. Basically, the spill prevention, the containment self equipment, has to have double wall, and integrity of both walls has to be monitored and then typically every 30 days. You need to, if you’re not going to monitor those from a manual perspective. If the facility seized and bring and delivery, then the you’re not going to have to monitor it in that fashion. But, however, the opera’s get discontinued. This periodic monitoring and they have to go to third days, to conduct the test which i’m going to scribe in the next slide. So on this particular aspect of it, the sylvers equipment contained sumps uses within a system. Monitoring have to be test at least every three years, so the bottom line is that, if you’re, using interstitial monitoring for containment and spill prevention, that you have to test it every three years, just multiple methods to test this, I’m not going to go through that. You can use as a reference as a down the road, but basically that you can. You can test the stumps through liquid and pressurizing it and then through vacuum, there’s many methods that they use today and then the last thing again still runs an equipment and payment sums using interstitial monitoring or going out again. I have to be starting to be tested for tightness after October 2015, now, let’s review the underground storage tank to release detection requirements. This is something that most of you know about if you’ve been around for a while. So these are the different types of methods you can use for your underground storage tank system. So you know basically monitoring methods that you can use and you have to basically prove this. Every 30 days you use a tank gauge system. You can use vapor that monitors vapor in the soil. You can use groundwater monitoring that monitors the liquid for hydrocarbons. You could use interstitial monitoring, SI r or sista tisco inventory reconciliation. You can use weekly manual tank gauging and you can also use annual tank techni testing with daily inventory control. When you do that number seven, then you have to do you get to bring something in once a year to do that test. Going back to the institutional monitor again for those tanks that are installed after april of 2016, they’re all going to be required to have interstitial monitoring for them, and this is a this – is the last slide I want to talk about.

This is the main inside of it um. It’S really important, because one thing that we found we find that Veta roof. Is that a lot of folks? If that they’re not required to do an annual certification, they won’t do it to make sure their equipments working. It’S like not taking your car in for an oil change because you just don’t like doing it, so this is really important because of all the regulations, all the requirements that you’re that you’re being asked to do it’s to your best interest to get somebody who’s a Certified trained technician to come out and perform those Daniel certifications for those tests. So one you have the records to prove it to any regulatory body and to just to make sure you have the protection at the site with the atg. That’S that the investment you made so again with the automatic tanking you get a test for alarms. You got to verify. The system is programmed, it has a battery backup. You got to make sure it works on the probes and the sensors of the site that you know we want you to inspect, for you know, and he build up on them. Make sure the floats move, make sure there’s no damage on the probes of the shafts. Make sure cables are free of debris, Kingston breaks and then cut the alarm operability of the system to make sure it works, and then, if you’re, using electronic leak detection, which you can with the V root system, you should have the technician perform a simulate, a leak For the three gallons per hour at 10, gallons per square inch, that that gives you a good feeling, knowing that your system is operational and it will detect a leak if there’s potential leak issue. And then, if you’re, using vacuum, pumps and pressure gauges, ensure there’s proper communications of those devices. Now there are four like vapor monitoring groundwater monitor. There are handheld devices, however, you got to make sure those handheld devices are working properly and they can sample properly so inspect them. If I need to be calibrated, make sure their caps they’re calibrated and again, you know, owners an operation. Let’S maintain records a release, detective mode testing for at least three years, so ultimately, you have to keep those records and then prove that to some regulatory agency at some point down the road really quick, just a highlight of the red jacket and cat little equipment. You know we have a lot of equipment in the field. We can monitor the tank for inventory, tank testing automatic reconciliation. We can reconcile your product, submersible pumps, get the product to the dispensers on the gift, and then we all sup mag probes, to do the inventory tank testing. And then we have multiple sensors to be able to monitor all this containment areas that we were talking about and and then again we have the overfill protection device that you can install at the tank area. That utilizes being in tank probe degenerate, got alarm, and then we use this with our customers, using our in the clouds sis servers inside 360 to be able to give you all that data at your fingertips.

So you have that visibility to be able to know that your sites in an overfilled condition and how is it he be addressed. So at that point John, and that’s what I have today and hopefully I was able to provide some insight to the folks on the phone. Great thanks Lee good presentation. I want to now open it up to two QA. I also want to point out here on the slide: we’ve got contact information. You know. If you have a technical issue, you need to get in touch with somebody at Peter ooh. That’S the best method there. My contact information is also there, but let’s go ahead and get started with questions got one here came in from the chat window. I can my overfill alarm be used for other alarm conditions to alert a driver. The answer yet the any atg that’s connected to an old Phil device. You can especially the vita routes. You can, you can program for any alarm condition so, for instance, the overfill alarm condition is the first alarm level. Typically that you want to alert the driver. You can have two more levels above that you have. I level look limit and then a maximum alarm, so you can actually create that alarm and have the alarm generate another buzz or another light indicator for that, and then, as other conditions off is you could set it up for okay, great thanks. Lee did have another question here. What types of mechanical failures are most common related to overfill alarms electronical with the alarms of the mechanical? I was in crowd, yeah, I’m sorry. I said what type of mechanical failures are most common related to overfill on the flapper valves. What we’ve seen as we’ve seen the float itself disengage and then the flapper valve won’t won’t actuate the flapper valve itself, the the mechanism the spring on it disengages and then that that potentially will not open and ultimately, if that’s, why they are asking for you to Test it periodically to make sure that that doesn’t happen. Okay, great, let’s see, I think we have time, maybe for one more question before we close it out and but just to mention to people that are on the phone. We are recording today’s session, and so we will have that available to share with people in in the next few days but did have a seat. Here’S a question does: does a flapper valve also create some pressurization in the tank, and I think they’re, alluding to you know like the ball valves is, and maybe it’s a question around. How are those different? Yes, a bit low because the ball valve is directly plugged into the little the vent line itself. Then that’s why it causes a pressure differential in the tank as the tank fills on the flapper valve. If they have the proper does stage 1 babe recovery hooked up back to the tanker, then the pressure should stay equal in the tank as they’re delivering product. So technically the flapper valve system doesn’t put pressure on the tank. Okay, great thanks. Yes, John up son, hey! I don’t remember if you mentioned at the beginning, but again you know folks who are on this webinar there.

You know, please fill out the survey, but you know, and also I filling out the survey gives you the opportunity to participate in a overfill alarm, promo that we’re going to we’re going to conduct for the folks have been on this call perfect. You just did my clothing for melee. Thank you. The next thing I was going to do, but again we’re right at the end of our time here, so we want to be cognizant of everyone’s time. I want to thank everyone for joining today Lee. Thank you for another good presentation and please be on the lookout for more of these EPA related webinars from us and again we’re recording today’s session and be sure to fill out the survey as you exit the presentation, and we thanks everyone for joining thanks.

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